In the case of Craig v. Amateur Softball Association of America,(Pa. Superior Ct. June 4, 2008), the plaintiff (who was not wearing a helmet at the time) was struck in the head by an errantly thrown ball while running the bases at a softball game. He claimed various physical injuries as a result. He subsequently sued the softball association that had sponsored the game and argued that the league had a duty to mandate or at least recommend the wearing of helmets. The trial court granted summary judgment for the defendant and the plaintiff appealed. The Superior Court affirmed the dismissal and held that the defendant association did not owe a duty to warn, protect or insure against risks that are “common, frequent, expected and inherent” to the injury causing activity.